                                       
                                     FINAL
                                       
TO:	Brian Storey,
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division
FROM:	Steven McLeod, RTI International
DATE:	December 1, 2021
SUBJECT:	Technology Review for the National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities Source Category  -  Proposed Rule
 I.	INTRODUCTION
Section 112 of the Clean Air Act (CAA) requires the EPA to establish technology-based standards for sources of hazardous air pollutants (HAP). For major sources, these technology-based standards are often referred to as maximum achievable control technology, or MACT, standards. For area sources, EPA may set generally available control technology, or GACT, standards, in lieu of MACT. Section 112 also contains provisions requiring the EPA to periodically review these standards. Specifically, paragraph 112(d)(6) states:
      (6) REVIEW AND REVISION.  -  The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than every 8 years.
The purpose of this memorandum is to present the findings of the technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for those dry cleaning facilities using perchloroethylene (PCE) as the cleaning solvent (PCE Dry Cleaning NESHAP). The title of this NESHAP is Perchloroethylene Air Emission Standards for Dry Cleaning Facilities, and is codified in title 40, part 63, subpart M of the Code of Federal Regulations (40 CFR part 63, subpart M). 
 II.	SUMMARY
Based on the findings of the technology review, we did not identify developments in new practices, processes, or control technologies, for purposes of this technology review, that were not identified and considered when the NESHAP was promulgated in 1993 or last reviewed in 2006.  However, we have identified developments in the widespread implementation of processes that had been identified and considered but have not yet been required for all subject sources, and these developments necessitate revision of the MACT and GACT standards of 40 CFR part 63, subpart M to keep up with these developments and preclude backsliding to higher emitting processes. Specifically, the findings support amendments to the rule requiring all dry-to-dry machines at both major and area sources to operate both refrigerated condensers and carbon adsorbers as secondary emissions controls.
Section III of this memorandum provides background information on the requirements of CAA section 112(d)(6), and a description of the source category and current requirements. Section IV of this memorandum discusses the review of available information on developments in practices, processes, and control technologies that have occurred since promulgation of the standards. Section V discusses the recommended revisions to the NESHAP based on the results of the review of developments in practices, processes, or control technologies in the perchloroethylene dry cleaning sector. 
 III. 	BACKGROUND 
 A.	Description of the Perchloroethylene Dry Cleaning Facilities Source Category and Requirements of the Current NESHAP
The PCE Dry Cleaning NESHAP was originally promulgated on September 22, 1993 (58 FR 49376), and was subsequently amended as follows: 
 December 20, 1993 (58 FR 66289), 
 June 3, 1996 (61 FR 27788),  
 September 19, 1996 (61 FR 49265), 
 December 14, 1999 (64 FR 69643), 
 July 27, 2006 (71 FR 42743), and 
 July 11, 2008 (73 FR 39871). 
The standards of the PCE Dry Cleaning NESHAP apply to all industrial and commercial dry cleaners that use PCE, which is the only listed and regulated air toxic emitted from dry cleaners in this source category. Air toxics, also called hazardous air pollutants, or HAP, are known or suspected to cause cancer or other serious health or environmental effects.
Dry cleaning is any cleaning process for textiles (clothing and other garments) using a solvent other than water. PCE is the prevalent liquid solvent used in dry cleaning. Operators in this industry provide dry cleaning and laundering services. They may also provide drop-off and pick-up sites for customers. In addition, establishments may offer specialty cleaning services for garments and textiles such as fur, leather, suede, wedding gowns, draperies, and pillows. This industry does not include coin-operated laundromats.
The following table lists the 2017 North American Industry Classification System (NAICS) code 812320 businesses. The 812320 NAICS code, which covers dry cleaning and laundry services (except coin-operated facilities) businesses, does not distinguish sources that use PCE as the dry cleaning solvent. Many of the dry cleaning facilities included in these NAICS codes are not covered under the PCE Dry Cleaning NESHAP because they do not use PCE solvent in the dry cleaning operations.
812320 NAICS CODE OPERATION TYPES REPRESENTING THE DRY CLEANING INDUSTRY[a]
Agents, laundry and dry cleaning
Fur garment cleaning services
Apparel pressing services
Garment cleaning (e.g., fur, leather, suede) services
Bobtailers, laundry and dry cleaning
Hand laundries
Cleaners, dry cleaning and laundry service (except coin-operated)
Hat cleaning services
Cleaning and dyeing plants (except rug cleaning plants)
Laundries (except coin-operated, linen supply, uniform supply)
Collecting and distributing agents, laundry and dry cleaning
Laundry and dry cleaning agents
Curtain cleaning services
Laundry drop-off and pick-up sites
Drapery cleaning services
Laundry services (except coin-operated, linen supply, uniform supply)
Drop-off and pick-up sites for laundries and drycleaners
Leather garment cleaning services
Drycleaner drop-off and pick-up sites
Pick-up and drop-off sites for drycleaners and laundries
Drycleaners (except coin-operated)
Pillow cleaning services
Dry cleaning plants (except rug cleaning plants)
Power laundries, family
Dry cleaning services (except coin-operated)
Suede garment cleaning services
[a] Source: https://www.naics.com/naics-code-description/?code=812320 
The July 27, 2006, final rule amendments (71 FR 42743) indicate that at that time there were approximately 34,000 dry cleaning facilities in the United States, approximately 28,000 of which used PCE. Those estimated counts of the number of overall dry cleaning facilities and PCE dry cleaner facilities were based on data prior to business impacts from the 2008 financial crisis; the novel coronavirus (COVID-19) pandemic of 2020-2021, recent shifts in consumer demands, changes in garment technologies, and changes in fashion trends. Additionally, dry cleaning machine conversions to alternative solvents and other factors have resulted in reductions in the number of PCE dry cleaning operations. Based on information provided by dry cleaning industry stakeholders, including trade organizations, the EPA estimates that the number of PCE dry cleaners decreased by 20 to 30 percent due to the 2008 financial crisis, the aforementioned demand trends in the industry, and increasing replacements of PCE operations with alternative solvent technologies. Additionally, the EPA estimates that another 10 to 15 percent of PCE dry cleaners have ceased operation due to financial impacts from the COVID-19 pandemic. As such, the EPA estimates that there are approximately 10,000 to 15,000 PCE dry cleaning facilities in the U.S.
All major source and area source PCE dry cleaning facilities are subject to the PCE Dry Cleaning NESHAP. Per §63.320, a dry cleaning facility is a major source if the facility emits or has the potential to emit more than 10 tons per year of PCE to the atmosphere. However, in lieu of measuring or determining a facility's potential to emit PCE emissions, a dry cleaning facility is a major source if: (1) it includes only dry-to-dry machine(s) and has a total yearly PCE consumption greater than 2,100 gallons as determined according to §63.323(d); or (2) it includes only transfer machine system(s) or both dry-to-dry machine(s) and transfer machine system(s) and has a total yearly PCE consumption greater than 1,800 gallons as determined according to §63.323(d). Any source that is not major is an area source.
1.	Types of Dry Cleaning Machines
Dry cleaning machines have evolved over time to better protect worker safety and health and the environment. Dry cleaning machines encompass five "generations" which are currently used in the United States.
1st Generation: transfer machines. These older and less expensive machines require manual transfer of solvent-laden clothing between a separate washer and dryer. Transfer machines were used exclusively until the late 1960s.
2nd Generation: dry-to-dry (vented). These machines are nonrefrigerated, dry-to-dry machines, using a one-step process that eliminates clothing transfer. Clothes enter and exit the machine dry. Second generation machines vent residual solvent vapors directly to the atmosphere from the machine washing drum when the machine is opened after the drying cycle or through a form of vapor recovery system during the aeration process. Some machines utilize either a carbon bed or water-cooled coils.
3rd Generation: dry-to-dry (non-vented). Dry-to-dry machines with refrigerated condensers were introduced in the late 1970s and early 1980s. These are non-vented ("closed-loop" system) machines, which are only open to the atmosphere when the machine door is opened. They recirculate the heated drying air vapors through a vapor recovery system and back to the drying drum. These machines provide considerable solvent savings and reductions in PCE emissions over their predecessors.
4th Generation: dry-to-dry (non-vented with secondary vapor control). Fourth generation dry cleaning machines are essentially 3rd generation machines with controls to reduce residual PCE in the machine cylinder at the end of the dry cycle. These machines rely on both a refrigerated condenser and carbon absorber to reduce the PCE concentration at the cylinder outlet below 300 parts per million (ppm) at the end of the dry cycle. These machines are much more effective at recovering solvent vapors than machines equipped with a carbon adsorber or refrigerated condenser alone.
5th Generation: dry-to-dry (non-vented with secondary vapor control and drum monitor). Fifth generation machines, most widely used in Germany but less so in the United States, have the same features as 4th generation machines. However, they also have inductive fans, a monitor inside the machine drum, and a sensor-actuated interlocking system to ensure that the concentration is below approximately 300 ppm before the machine loading door, button trap, or filters can be opened.
Note: The typical useful life of a PCE dry cleaning machine is 10 to 15 years.
2.	Key Requirements of the Current PCE Dry Cleaning NESHAP
In general, the PCE Dry Cleaning NESHAP affects three types of dry cleaners that use PCE: commercial, industrial, and co-residential. Commercial facilities clean household items such as suits, dresses, coats, pants, comforters, curtains, leather clothing, and formal wear. Industrial dry cleaners clean heavily-stained articles such as work gloves, uniforms, mechanics' overalls, mops, and shop rags. Co-residential is typically a subset of commercial operations but includes those dry cleaning facilities are located in buildings in which people reside and are usually found in urban areas where commercial and residential occupancy occur in a single building. 
The PCE Dry Cleaning NESHAP identifies all major sources as "large" industrial and commercial dry cleaners. These dry cleaners are subject to MACT standards under this NESHAP. From discussions with state air regulators, state small business environmental assistance providers' programs (SBEAP) personnel, and industry trade association representatives, it is estimated that there are five or fewer of these major source dry cleaners remaining in the United States. The rule requires new major source PCE dry cleaners operating dry-to-dry machines to: 
 Operate with a refrigerated condenser and carbon adsorber process controls.
 Use enhanced leak detection and repair (LDAR) program to detect PCE leaks from the machines (i.e., PCE gas analyzer operated according to EPA Method 21), repair the leaks, and maintain records.
The PCE Dry Cleaning NESHAP requires existing major source PCE dry cleaners operating dry-to-dry machines to:
 Operate with a refrigerated condenser or a carbon adsorber as process control.
 Use enhanced LDAR program to detect PCE leaks from the machines (i.e., PCE gas analyzer operated according to EPA Method 21), repair the leaks, and maintain records.
Dry cleaners that are commonly found in community settings (e.g., shopping centers and strip malls) or as stand-alone buildings are typically "area sources" of HAP, meaning they are not major sources because they emit less than 10 tons of PCE each year. These dry cleaning operations are typically smaller in size in comparison to large industrial and commercial PCE dry cleaners. The PCE Dry Cleaning NESHAP requirements for these area sources GACT standards. 
The PCE Dry Cleaning NESHAP requires existing area source PCE dry cleaners operating dry-to-dry machines to: 
Use a halogenated hydrocarbon detector or PCE gas analyzer monthly to detect PCE leaks, repair the leaks, and maintain records.
    
 New area source PCE dry cleaners operating dry-to-dry machines must:
 
Operate with a refrigerated condenser and carbon adsorber process controls. 
Use a halogenated hydrocarbon detector or PCE gas analyzer to detect PCE leaks, repair the leaks, and maintain records.
    
The 2006 amendments to the PCE Dry Cleaning NESHAP eliminated the use of PCE by dry cleaners in co-residential buildings (e.g., a dry cleaner found on the ground floor of an apartment building). EPA recognized that because co-residential dry cleaners are located very close to residences, residents' exposures and their cancer risks could be much higher than for typical area source dry cleaners. As such, the PCE Dry Cleaning NESHAP includes requirements to eliminate risks associated with PCE emissions from co-residential dry cleaners. Under 40 CFR 63.322(o)(5)(i), owners/operators were required to eliminate any PCE emissions from systems located in residential buildings by December 21, 2020. These dry cleaner owner/operators were allowed to replace PCE machines with newer available non-PCE technology. This sunset date allowed owners of existing co-residential sources to operate their machines for their maximum estimated useful life, 15 years, assuming they were first installed no later than December 21, 2005. Additionally, under 40 CFR 63.320(b)(2)(ii) and 63.322(o)(5)(ii), any PCE dry cleaning machines in co-residential buildings that began operating between December 21, 2005 and July 13, 2006, were required to install equipment to aggressively control PCE emissions (i.e., refrigerated condensers, carbon adsorbers, and vapor barriers), and to conduct weekly inspections to detect PCE leaks, repair the leaks, and maintain records, before eliminating PCE emissions by July 27, 2009.
 IV.	DEVELOPMENTS IN PRACTICES, PROCESSES, AND CONTROL TECHNOLOGIES
For the purposes of this technology review, a "development" is defined as the following: 
Any add-on control technology or other equipment that was not identified during the development of the NESHAP for the source category; 
Any improvements to existing add-on control technology or other equipment (that were identified and considered during development of the NESHAP standards) that could result in additional HAP emissions reductions;
Any work practice or operational procedure that were not identified or considered during development of the NESHAP for the source category; or 
Any applicable process changes or pollution prevention alternatives that could be broadly applied to the source category that were not identified and considered during the development of the NESHAP for the source category.
The EPA investigated developments in practices, processes, and control technologies through the following means:
       Discussions with state agencies (including regional, state, and local regulators) and SBEAP personnel, 
       Discussions with industry stakeholders and trade association representatives, 
       Web searches for technical literature and information, and 
 Searches of the EPA's Technology Transfer Network (TTN) Clean Air Technology Center  -  RACT/BACT/LAER Clearinghouse (RBLC) database. 
The results are presented in the following sections.
 A.	Input from States
The EPA met (via multiple conference calls) with several state air agencies and SBEAP representatives to gather information and details pertaining to developments in practices, processes, and control technologies in the PCE dry cleaning sector. 
The states contacted for discussion were selected based on several factors. These factors included the states' robust state-level programs in place for regulating and tracking the dry cleaning sector's environmental impacts, the level of emissions details reported by the states in the 2017 National Emissions Inventory (NEI) report, and states from various regions of the US (northeast, south, midwest, west, etc.).  The EPA selected states that represented a cross-section of dry cleaning industry from around the country.
The following comments pertaining to the PCE dry cleaning industry and developments in practices, processes, and control technologies were shared universally by all of the state stakeholders:
 There have been no new developments in new technologies or practices for reducing air emissions in the PCE dry cleaning sector since the last technology review in 2006 identified and considered available technologies and practices.
 There has been a significant reduction in the number of PCE dry cleaning facilities since the last technology review. The reduction in the number of facilities is due to several factors including changes in economic and market trends, facilities switching to alternative solvent dry cleaning and wet cleaning, changes in fashion preferences and changes in clothing fabric materials, environmental regulations (including air, hazardous waste, wastewater, and remediation requirements), and changes in the available workforce to run and manage these operations.  In addition. some companies with multiple store locations have consolidated the use of PCE to a single location, and converted the multiple locations to "drop-off" only locations (i.e., garments are collected at the satellite locations and then transported to the centralized location to be cleaned). 
 The downward trends in the PCE dry cleaning industry began prior to the effects of the COVID-19 pandemic and have only been exacerbated by the associated health impacts, stay-at-home mitigation measures, and economic impacts of the pandemic.
 The popular alternatives being used in the dry cleaning sector in place of PCE-based dry cleaning machines are high-flashpoint hydrocarbon dry cleaning solvents (e.g., DF2000, Sensene(TM), and EcoSolv(R)), liquid carbon dioxide (CO2), GreenEarth (siloxane-based solvent), SolvonK4(TM) (bio-based solvent), petroleum, and water (wet cleaning). 
 N-Propyl bromide (1-bromopropane, nPB or 1-BP), was once touted as a drop-in replacement for PCE dry cleaning machines but, according to the state stakeholders, is no longer used as a drop-in replacement, and proved to damage machines due to its corrosive properties.
Other state-specific salient points on dry cleaning that these stakeholders shared with the EPA on these calls are summarized by state below. The specific dates, times and attendees for each meeting are provided in Appendix A of this memorandum.
1.	California Air Resources Board (CARB)
In 2007, California passed Airborne Toxic Control Measures (ATCM) legislation, which phased-out the use of PCE within 15-17 years (the length of time designated as the typical useful life of a PCE dry cleaning machine). This phase-out was written into the air permits of dry cleaning facility air permits. Only a handful of dry cleaners have not yet phased out PCE and by January 1, 2023, there will be no PCE dry cleaners allowed to operate in the state of California. (Note: wet cleaning and CO2 cleaners do not require permits in California.). CARB provides a list of PCE alternative solvents used in California dry cleaning facilities.
California created a grant program to aid those cleaners who decided to switch from PCE to alternative solvents. CARB representatives indicate 140 grants were issued. The state provides $10,000 if a facility converts to wet cleaning or CO2 cleaning. The state also offers an additional $7,500 if the facility conducts a demonstration of their new machine.
Most facilities in California have gravitated to using high-flash point hydrocarbon solvents (e.g., DF 2000[TM], EcoSolv(R), Sensene [TM]) or other alternative solvents such as silicone-based solvents (e.g., GreenEarth(R), D5, siloxane). 
The South Coast Air Quality Management District (SCAQMD) required the elimination of PCE in dry cleaning by the year 2020 (with some exception given due to COVID-19). 
The SCAQMD performs analyses on alternative solvents and maintains an approved alternative solvent list and list of professional cleaners that use PCE alternatives. New solvent candidates are sent to CA Office of Environmental Health Hazard Assessment (OEHHA) for toxicology evaluation. 
There were approximately 4,000 dry cleaning facilities in the 1990s (2,300 were PCE dry cleaners). In 2006, the total number dropped to around 3,000. As of the end of 2019, there were 300 PCE dry cleaners still operating in California (of which the SCAQMD had 270).
CARB evaluated health risks from dry cleaning facilities and decided to phase out co-located residential facilities first, then proceeded with the phase out of the remining PCE dry cleaning machines based on the age (useful life) of the machine. 
CARB has not seen substantive challenges with subject dry cleaners complying with the PCE Dry Cleaning NESHAP in California.
2.	Colorado SBEAP
In 2014, Colorado amended their state air regulations to require any facility that emits 250 pounds or more per year of any individual non-criteria pollutant (i.e., HAPs and other reportable pollutants) to submit an Air Pollutant Emission Notice (APEN) every five years. As such, dry cleaners that emit PCE at or above the 250 lb threshold must submit an APEN. Also, an air permit must also be obtained if the facility emits 10 or more tons of PCE per year.
There were approximately 1,000 PCE dry cleaning facilities registered and permitted in Colorado at the time of the most recent PCE Dry Cleaning NESHAP amendments in 2006. Currently there are approximately 70 PCE dry cleaners. 
The Colorado SBEAP is unaware of any major source dry cleaning facilities in Colorado.
In recent years, due to negative press and public response over remediation/hazardous waste/water issues, landlords had been pressuring dry cleaners to either move out or switch to "greener" solvents.
Colorado mails out compliance calendars to dry cleaners as an outreach program. The majority of dry cleaners in the state are Korean-owned, so the calendars are published in English and Korean. Also, the Colorado air group works with the hazardous waste group to provide environmental assistance and outreach to dry cleaner owner/operators.
There are no additional fees charged by the state for PCE usage (outside the normal annual air emissions and hazardous waste fees).
Dry cleaners in Colorado are operating 4th and 5th generation machines. 
Some facilities tried using petroleum as a drop-in replacement for PCE, but they ran into corrosion and gasket fouling issues.
Compliance issues are typically related to recordkeeping and leak checks, as well as a general lack of understanding the regulation and language barriers. The SBEAP generally encounters more hazardous waste issues with PCE dry cleaners as compared to air issues.
3.	Illinois EPA Bureau of Air and Illinois SBEAP
Illinois, via the Illinois EPA Bureau of Land, runs the Dry Cleaner Environmental Response Trust Fund. Through that agency and the Illinois State Department of Revenue, dry cleaners must be licensed according to the annual amount of solvent used. The Bureau of Land publishes a list of Illinois facilities with a current license.
Illinois requires dry cleaners to report annual PCE usage.
Dry cleaner compliance notebooks are issued by the state in January each year.
There is only one major source in the state (a facility located in Chicago).
Illinois personnel noted anecdotally that from discussions and observations of dry cleaning entities, if a dry cleaning business is purchased by a new owner/operator, they are switching from PCE to petroleum.
4.	Kentucky Division of Air Quality
The Kentucky Division of Compliance Assistance created a dry cleaning calendar. It provides facilities with a 2-year compliance calendar that allows facilities to record information such as weekly inspections, monthly PCE usage quantity, and twelve-month rolling averages. In addition, as outreach to the dry cleaning owners and operators, Kentucky provides a guidance document that has information on air, hazardous waste, and water regulatory compliance requirements.
Kentucky Division of Air Quality (DAQ) provided EPA with the following dry cleaning inventory details: 
Currently there are 56 facilities using PCE.
Since 2003, there have been 22 facilities that stopped using PCE and moved to using alternative solvents.
Since 2003, 25 facilities stopped dry cleaning at their location and are used as a drop-off/pick-up site.
Since 2003, 100 dry cleaning facilities have closed.
No records indicate that there are any PCE Dry Cleaning NESHAP major sources.
Only two co-residential facilities were found in records dating back to 2003 and both have closed.
Kentucky DAQ regulators' discussions with Kentucky field inspectors indicate that a common reason why facilities have moved away from using PCE is the cost of the solvent.
5.	New York State Department of Environmental Conservation (NYDEC)
There has been a general decline in dry cleaning businesses, mainly due to market trends, but also somewhat due to landlord pressures about having PCE dry cleaning on their properties. These businesses are difficult to relocate as customer bases tend to be location-centric.
New York fire department codes are more stringent that national standards. Compliance with those codes makes it difficult to site alternative solvent machines (particularly high flashpoint hydrocarbon machines).
In 2006, there were approximately 1,500+ facilities statewide. Currently there are around 1,200 facilities statewide (with more than half being in New York City).
150 co-located residential facilities have been shut down since the 2006 PCE dry cleaning NESHAP rule amendments. NYDEC updated the state rule in 2018 to include co-located residential facility phase out (no PCE in co-located residential after December 21, 2020, consistent with PCE Dry Cleaning NESHAP). Some co-located residential facilities are yet to be deactivated in the database (so there are likely less than 1,200 facilities actually in operation). Field inspections were paused due to the COVID-19 pandemic and are expected to resume in summer-fall 2021. As operations are verified, the data will be updated.
If an owner or operator wants to relocate a PCE machine in New York, the machine must be less than 10 years old, and the new location must be a stand-alone location on a property owned by the operator.
The state of New York used to only require major facilities to test end-of-cycle concentrations in the drum; now every PCE machine owner must do monthly sampling of 4th generation machines (with colorimetric detector tube sampler or photo ionization detector). 
3rd generation and older machines cannot do this type of testing.
The limit is 300 ppm PCE in the drum.
Yearly compliance inspections are conducted by third-parties (which are funded by the regulated facilities).
State regulations ban 3rd generation machines after December 31, 2021. In 2017, there were approximately twenty 3rd generation machines. Currently there are eight 3rd generation machines (these will be discontinued by the end of 2021).
State of New York has seen no breakthrough changes in design that would limit emissions since mid-2000s (last technology review).
New York performs analyses on alternative solvents and maintains an approved alternative solvent list.
New and existing facilities installing new PCE dry cleaning machines, must submit a Notification of Compliance Status form to the NYDEC within 30 days of commencing operation. Additionally, facilities with a calculated yearly PCE consumption that exceeds 2,100 gallons, must submit this within 180 days from the date of determination.
NYDEC representatives are not aware of any 5th generation (door lock out mechanism until cycle ends) in New York from inspection findings and records reviews. 
N-propyl bromide (1-BP) is not allowed as a dry cleaning solvent in New York due to toxicity.
It is estimated that there are one or two major sources (industrial cleaners) under the dry cleaning NESHAP in the State. But none are major based solely on PCE usage.
The State of New York recommends dry cleaners attend a 16-hour training class.
To operate a PCE dry cleaning facility in New York, the owner or manager must have a valid Owner/Manager certificate. To operate a PCE dry cleaning machine, the operator must have a valid operator certificate.
6.	North Carolina SBEAP
Transfer machines are no longer used, and 4th generation machines are typical in North Carolina.
North Carolina laws pertaining to reclaimed PCE require closed-loop fill capture system for removing PCE from one dry cleaning machine for the purposes of introducing the used/reclaimed PCE into another dry cleaning machine. This was difficult to achieve in practice, and the law ended up discouraging PCE reclamation.
There is no 1-BP being used as solvent in North Carolina dry cleaning facilities. That solvent had been billed as PCE drop-in replacement, but the one facility that tried using it had heavy rusting and corrosion issues.
CO2 dry cleaning was also touted as a PCE alternative, but it is a large investment (including purchasing a supercritical pressure vessel). 
7.	Rhode Island Air Division
There were approximately 83 PCE dry cleaning facilities in Rhode Island in 2006, and there are approximately 39 in the state currently. None of these are major sources. No new PCE machines have been purchased and installed in recent years.
The most common alternative solvent in use in Rhode Island is high flashpoint hydrocarbons.
Occasional problems encountered during inspections were related to language barriers; for example, understanding where to purchase colorimetric detection tubes. Additionally, lack of the proper recordkeeping was also noted by Rhode Island inspectors.
Mostly closed-loop 4th and 5th generation machines are in use, with less than five 5th generation machines installed.
8.	Tennessee Air Division and Remediation Division
Tennessee requires all active dry cleaning facilities to register with the state's Dry cleaner Environmental Response Program (DCERP). Registration fees go toward a voluntary clean-up program. Also, fees are charged for solvent.
Dry cleaning owner/operators must follow DCERP's Best Management Practices (BMPs). The DCERP BMPs are designed to make sure solvent and waste are handled safely.
Tennessee switched from issuing individual permits for dry cleaning facilities to making general permits for dry cleaners. General permits are single permits issued by the Technical Secretary of the Tennessee Air Pollution Control Board for a specific type of facility and inspections are performed on those permitted facilities. The general permits are not issued to a specific facility. Sources can choose to be covered under a general permit, if eligible, or they can request a traditional permit if they prefer. The issuance date of the general permit for PCE dry cleaners is February 2, 2017, and the expiration date is February 1, 2027.
Tennessee classifies cleaning solvents into two categories: where PCE is classified as "dense" (i.e., heavier than water), and some of the alternative solvents are classified as "light" meaning they float on water (e.g., DF2000, EcoSolv, Stoddard, oxygenated constituents) 
Over the last few years (before the COVID-19 pandemic) Tennessee saw a decrease in the number of facilities at a rate of 5-10 facilities closing business per year. As a result of the COVID-19 pandemic, it is estimated that 25 to 30 facilities in the state have closed in 2020 through spring 2021.
Approximately 50 percent of the existing dry cleaners are using PCE and 50 percent are using hydrocarbons. New machines are primarily hydrocarbon machines.
There are currently 195 registered dry cleaners in the state, which is a decrease from 2016, when there were 286.
Currently there are 69 PCE dry cleaning facilities subject to the PCE Dry Cleaning NESHAP. This does not include data from the metro areas.
No Title V dry cleaning facilities (largest facility in the state uses hydrocarbon not PCE)
Tennessee uses three categories for dry cleaning machines: 
Dry-to-dry installed on or before December 9, 1991, that use less than 140 gallons of PCE per year;
Dry-to-dry machines installed after December 9, 1991, and before December 21, 2005, equipped with refrigerated condenser using pressure gauges and/or temperature sensors; and
Dry-to-dry machines installed after December 21, 2005. Machines in this category must follow the requirements under the PCE Dry Cleaning NESHAP.
Tennessee state regulators have observed an increase in conversions from full service to drop off/pick up only locations
There are no hydrocarbon drop-in solvent replacements for PCE machines (or vice versa). Owners and operators have to get entirely new machines to use hydrocarbon solvents.
 B.	Dry Cleaning Industry Trade Associations
The EPA met (via multiple conference calls) with representatives from three major membership-based dry cleaning industry trade associations  -  the Dry Cleaning & Laundry Institute (DLI), National Cleaners Association (NCA), and Korean Dry Cleaners Association (KDCA). The purpose of the outreach to these trade associations was to gather details related to developments in practices, processes, and control technologies and are summarized below. The salient points that these stakeholders shared with the EPA on these calls are summarized in this section. The specific dates, times and attendees for each meeting are provided in Appendix A of this memorandum
As a result of the PCE Dry Cleaning NESHAP regulations and OSHA occupational health regulations, dry cleaners have moved to using 4th generation (or better) machines on a widespread basis.
There have been no significant technology changes since the EPA's prior technology review in the mid-2000s.
The PCE Dry Cleaning NESHAP requirements have resulted in reductions of the number of PCE dry cleaners. For example, there used to be approximately 4,000 facilities in the state of New York (2,000 in New York City); now there are under approximately 2,000 statewide (with 1,000 in New York City).
None of their members are using transfer machines and none have purchased 3rd generation or older machines.
Based on DLI records, there are only a handful (i.e., less than 5)  -  if any at all  -  major source dry cleaning facilities as defined by the PCE Dry Cleaning NESHAP that are still in operation.
No owner/operators are installing PCE machines if it is a new business. They install alternative solvent machines.
Most new dry cleaning operations that came online within the last 5-10 years use alternative solvents. These alternative solvents primarily include hydrocarbons, GreenEarth, K4, and Sensene. Alternative solvents in use do not include 1-BP. Some owner/operators continue switch over to hydrocarbon or other alternative solvents to stay in business, while others have closed their operations.
Some cleaners have adopted CO2 and wet cleaning as alternatives to PCE.
Dry cleaners know that PCE use is heavily regulated (i.e., air, waste, remediation) and the industry is scrutinized closely due to negative press associated with PCE. These reasons along with economic factors have resulted in a decline in the number of PCE dry cleaners. 
The number of operating dry cleaners has been in a downward trend for years and the COVID-19 pandemic has exacerbated an industry already in decline. The primary reason for the downward trend is that consumer trends have reduced the need for dry cleaning of clothing. 
To stay in business and supplement the decline in dry cleaning, facilities have had to pivot their focus to laundering, wet cleaning, and other ancillary services.
Larger cleaners are centralizing their operations by using a single operating plant location and then using their other sites for pick-up/drop-off stores.
 C.	Web Searches for Technical Literature
Web search queries for technical literature pertaining to dry cleaning sector developments, trends, emissions controls, etc. did not identify any developments in new practices, processes, or control technologies that were not previously identified and considered and have been implemented in this source category since promulgation of the NESHAP following the last technology review on July 26, 2006 (71 FR 42724), beyond widespread use of fourth generation (or better) systems that were not previously required for all sources. 
Some of the primary web sources that were reviewed for the technology review are provided below (this is not an exhaustive comprehensive list of all the web sources that were reviewed):
 Amended Dry Cleaning Air Toxic Control Measure Requirements, CARB, March 2007  https://ww2.arb.ca.gov/sites/default/files/classic/toxics/dryclean/factsheet2016.pdf 
 Brooklyn's Dry Cleaners Worry About New Regulation, Yeong-Ung Yang, August 2016  http://brooklynink.org/2016/08/12/54973-brooklyns-dry-cleaners-worry-about-new-regulations/ 
 California Dry Cleaning Industry Technical Assessment Report, CARB Stationary Source Division Emissions Assessment Branch, February 2006  https://ww2.arb.ca.gov/sites/default/files/classic/toxics/dryclean/finaldrycleantechreport.pdf 
 Clean Air Guide for Dry Cleaners, Washington D.C. Department of Energy and Environment, https://doee.dc.gov/service/clean-air-guide-dry-cleaners 
 Comparison of Professional Garment Cleaning Processes, Suffolk County Department of Health Services, October 2018  https://www.suffolkcountyny.gov/Portals/0/FormsDocs/health/Administration/2018-10-31%20Revised%20Final%20Report%20SCDHS%20Garment%20Cleaning.pdf 
 Conducting Contamination Assessment Work at Drycleaning Sites, State Coalition for Remediation of Drycleaners, October 2010  http://astswmo.org/files/Resources/SCRD/Conducting-Contamination-Assessment-Work-at-Drycleaning-Sites.pdf 
 Coronavirus Pandemic Upends the Dry Cleaning Industry, Odette Yousef (NPR), March 2021  https://www.npr.org/2021/03/31/982953808/coronavirus-pandemic-upends-the-dry-cleaning-industry  
 Dry Cleaners Industry in the US - Market Research Report by IBISWorld, February 2021  https://www.ibisworld.com/united-states/market-research-reports/dry-cleaners-industry/ 
 Dry Cleaning: Alternative Solvent Trends, Misconceptions, and State of the Industry presentation, Jon Meijer - DLI Director of Membership, February 2020  https://www.youtube.com/watch?v=P5ij7ETDVIM 
 Dry Cleaning Alternatives  -  How "Green" is Green?, Garret Ponzi, September 2017  https://eriskinnovations.com/dry-cleaning-alternatives-how-green-is-green/ 
 History of Dry Cleaning Solvents and the Evolution of the Dry Cleaning Machine, Dru Carlisle  https://www.enviroforensics.com/blog/the-history-of-dry-cleaning-solvents-and-the-evolution-of-the-dry-cleaning-machine/ 
 Reflections on the 2008 Recession, Jeff Carnahan, April 2020  https://www.enviroforensics.com/blog/reflections-on-the-2008-recession/ 
 U.S. Dry Cleaning Corporation  -  US Securities and Exchange Commission Filing Form SB-2/A, April 2007  https://www.sec.gov/Archives/edgar/data/920317/000101968707001141/usdry_sb2a3-041907.htm 
 Waste and Emission Reduction Alternatives for Dry Cleaners, Oklahoma Department of Environmental Quality, July 2021  https://www.deq.ok.gov/wp-content/uploads/2021/06/WasteEmissionReductionDryCleaners_07-2021.pdf 
 What's Next for the Drycleaning Industry as the U.S. Begins to Reopen? Industry leaders Share Their Opinions, Mary Scalco, et. al, April 2021  https://www.enviroforensics.com/blog/whats-next-for-the-drycleaning-industry-as-the-u-s-begins-to-reopen-industry-leaders-share-their-opinions/ 
 D.	RBLC Search
Under EPA's New Source Review (NSR) program, if a company is planning to build a new plant or make a major modification to an existing plant such that criteria air pollution emissions will increase by a certain amount, then the company must obtain an NSR permit. The NSR permit is a construction permit, which generally requires the company to minimize air pollution emissions by changing the process and/or installing air pollution control equipment. The terms "BACT", "LAER", and "RACT" are acronyms for different requirements relevant to the NSR program. Best Available Control Technology, or BACT, is required on new or modified major sources in areas meeting the national ambient air quality standards (i.e., attainment areas). Lowest Achievable Emission Rate, or LAER, is required on new or modified major sources in non-attainment areas. Reasonably Available Control Technology, or RACT, is required on existing major sources in non-attainment areas. BACT and LAER (and sometimes RACT) are determined on a case-by-case basis, usually by state or local permitting agencies. 
The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central database of air pollution control technology information (including past BACT and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case-by-case determinations. The RBLC contains over 8,000 air pollution control permit determinations that were submitted by all 50 states and several U.S. territories on over 200 different air pollutants and 1,000 industrial processes. It was designed to help permit applicants and reviewers identify appropriate technologies and pollution prevention concepts to mitigate most air pollutant emission streams for stationary air pollution sources. 
The RBLC provides several options for searching the permit database online to locate applicable control technologies. Searches on the RBLC database were conducted using the time frame of January 1, 2000, to the date of the RBLC search (May 27, 2021). The RBLC lists determinations for two process types that are potentially applicable to this subpart:
Process Type: 49.002  -  Dry Cleaning, PERC/Chlorinated Solvents
Process Type: 49.003  -  Dry Cleaning, Petroleum Solvents
For the specified timeframe, no results were returned when searching for Process Type 49.002. Three results were returned for Process Type 49.003, however none of the information returned was more recent than 2005 or include any new or improved control technologies. 
In addition to searches conducted using the process type codes above, the RBLC was queried for any sources with "cleaning," "cleaners," or "dry cleaning" in their name. The NAICS and SIC codes for dry cleaners, 812320 and 7216, respectively, were also used to search the RBLC. None of these searches returned relevant information on new or improved control technologies used in dry cleaning facilities, that not been previously identified and considered. 
 E.	Control Technologies
As identified in the December 2005 proposed rule (70 FR 75884), three types of emission control technologies can be used to reduce PCE emissions from dry cleaning machines using PCE as a solvent. The first two are a refrigerated condenser and a secondary carbon adsorber. The third technology is a PCE sensor and lockout. By using the first two control technologies together, and by operating them properly, a significant amount of PCE can be recovered as described below.
Refrigerated condensers are the most effective method for reducing PCE from the drying cycle. They are used to condense PCE vapor for reuse. The refrigerated condenser is a vapor recovery system into which an air-perchloroethylene gas-vapor stream is routed and the PCE is condensed by cooling the gas-vapor stream. The air remaining in the machine at the end of the dry cleaning cycle then passes through a carbon adsorber prior to opening the machine door (or as soon as the door to the machine is opened). By operating at lower temperatures than water-cooled condensers, refrigerated condensers recover more PCE from the drying air and reduce emissions. By the end of the cool-down cycle, refrigerated condensers can reduce PCE concentrations in the drum to between 2,000 and 8,600 ppm. Refrigerated condensers require relatively little maintenance, needing only to have their refrigerant recharged and to have lint removed from the coils (yearly or even less frequently). 
A secondary carbon adsorber controls the PCE emissions during the final stage of the dry cleaning cycle just prior to the drum door opening. A carbon adsorber removes organic compounds from air by adsorption onto a bed of activated carbon as the air passes over the bed. Carbon adsorbers have a PCE removal efficiency of 95 percent or greater. Properly designed and operated secondary adsorbers have been shown to reduce the PCE concentration in the drum from several thousand ppm to less than 100 ppm, and in some cases, to less than 10 ppm. New dry cleaning machines sold today are 4th or 5th generation and thus are equipped with secondary carbon adsorbers. Carbon adsorbers require periodic desorption (in accordance with manufacturer's instructions) to recover PCE and maintain their peak PCE collection efficiency.
A PCE sensor is the third control technology used in machines with a secondary carbon adsorber. The sensor controls the carbon adsorption cycle to achieve a set PCE concentration in the drum. This device uses a single-beam infrared photometer to measure the concentration of PCE in the drum and prolongs the carbon adsorption cycle until the concentration set point is achieved. An interlock (lock-out) ensures that the PCE set-point has been attained before the machine door can be opened. Although this lock-out device (found on 5th generation machines) provides additional safety for operators, if a machine is allowed to complete the drying cycle, the carbon adsorber of a 4th generation machine provides the same level of PCE emissions control.
Based on the current results of online research, publication reviews, and discussions with industry regulators and trade groups, the control techniques described above are still in use by PCE dry cleaning operations. No developments in new control technologies have been identified in this review, beyond the widespread use of fourth generation (or better) systems that had not been previously required for existing sources.
 F.	Process Controls 
No new process controls were identified as part of this technology review, beyond the widespread use of fourth generation (or better) systems.
However, there have been developments in practices, processes, and control technologies that had been identified and considered at the time of adoption of the original NESHAP and/or of the last technology review in 2006. These developments reflect a widespread transition away from some practices that had been allowed to continue for existing sources but were not permitted for new or reconstructed sources. In this technology review, for example, the EPA confirmed with industry representatives that the useful life of a dry-to-dry machine is 15 years. In accordance with the PCE Dry Cleaning NESHAP, PCE dry cleaning machines installed after 1993 for major sources and 2005 for area sources would be equipped with refrigerated condensers and carbon adsorbers. Therefore, the EPA is proposing to require all sources subject to the PCE Dry Cleaning NESHAP, whether new or existing, to be equipped with refrigerated condensers and carbon adsorbers in order to reflect this development.
 G.	Pollution Prevention/Work Practices
The primary pollution prevention/work practice techniques used in PCE dry cleaning operations are visual inspections, perceptible leak inspections of dry cleaning machine components, and leak detection and repair using a halogenated hydrocarbon detector or PCE gas analyzer that is operated according to the manufacturer's instructions (according to EPA Method 21 for major sources). 
A NIOSH technical report, Control of Health and Safety Hazards in Commercial Drycleaners: Chemical Exposures, Fire Hazards, and Ergonomic Risk Factors, provides the following list of recommendations related to proper work practices:
Solvents or hazardous waste should never be left standing in an open container.
Dry cleaning machines should never be loaded beyond the manufacturer's capacity rating. Drying times and temperatures should be regularly monitored.
All ventilation systems within the dry cleaning room should be operating when the dry cleaning machine is in operation.
All forms of machine maintenance should be performed when the machine and solvent are under cold conditions. Machine maintenance, such as cleaning the button/lint trap, should never be performed when the machine is in operation.
Machine maintenance should be performed on a routine basis, in accordance with machine manufacturer's guidelines.
All doors on dry cleaning machines should be opened for a minimal amount of time.
Leak checks should be regularly performed, and any leak that is identified should be immediately repaired.
The report further notes that many of the modern machines have design features that will compensate for poor work practices that may cause high exposures. For example, operators should not exceed the machine's rated capacity, shorten the drying cycle, or open machine doors while the machine is operating because each of these activities will increase worker exposure. Fifth generation machines are designed so that the dry cycle cannot be shortened and if the machine is overloaded, the dry cycle will run longer to compensate. Furthermore, many of the machine doors are locked and cannot be opened while the machine is in operation.
No developments in these previously identified and considered pollution prevention/work practice measures have been identified in this review.
 H.	Alternative Solvents to PCE
The EPA re-examined the use of alternative solvents in use by the dry cleaning industry. This includes the use of non-PCE containing products such as silica-based solvents and high flash point hydrocarbon solvents. As part of this assessment, the EPA reviewed the list of alternative solvents identified in the 2006 PCE Dry Cleaning NESHAP RTR, and found that, for the purposes of the PCE Dry Cleaning NESHAP MACT or GACT standards, the list of alternative solvents available to the dry cleaning industry remains essentially the same. Since our 2006 assessment, there have been some products that are no longer marketed, and a few products added to the list. For this technology review, we found that alternative solvents continue to offer an alternative to PCE use. In the 2006 PCE Dry Cleaning NESHAP RTR we looked at the use of alternative solvents as it relates to a potential ban of PCE use, and after reviewing our assessment made for the 2006 final rule, we have found no new information that would change our 2006 assessment for purposes of the MACT or GACT standards for this source category.

 V.	CONCLUSIONS: RECOMMENDED REVISIONS BASED ON DEVELOPMENTS IN PRACTICES, PROCESSES, AND CONTROL TECHNOLOGIES
This review identified no developments in new practices, processes, or control technologies since promulgation of the current PCE Dry Cleaning NESHAP that had not been previously identified and considered. No revisions to the NESHAP emission limits are recommended based on the RBLC search and the review of new previously unconsidered add-on controls, process controls, and pollution prevention. 
However, there have been developments in the industry's use of practices, processes and control technologies that had been identified and considered at the time of adoption of the original NESHAP and/or of the last technology review in 2006.  These developments have reflected a widespread transition from some practices that had been originally allowed to continue for existing sources during their useful lives but were not permitted for new or reconstructed sources. Specifically, based on the ubiquitous use of 4th and 5th generation dry-to-dry PCE dry cleaning machines and given that any 3rd generation or older machines are now well beyond their useful life (15 years) since the 2006 risk and technology review, it is recommended that EPA propose to phase out all 3rd generation and older PCE machines as a development in practices, processes and control technologies. 
3rd generation dry-to-dry non-vented machines with refrigerated condensers were introduced 40 years ago. 4th generation dry-to-dry non-vented machines advanced on the 3rd generation technology by adding secondary vapor control to reduce residual PCE in the machine cylinder at the end of the dry cycle. These machines are equipped with both a refrigerated condenser and carbon absorber to reduce the PCE concentration at the cylinder outlet below 300 ppm at the end of the dry cycle. These 4th generation machines are much more effective at recovering solvent vapors than 3rd generation (and older) machines equipped with a carbon adsorber or refrigerated condenser alone.
Like 4th generation machines, 5th generation machines are dry-to-dry non-vented with secondary vapor control. However, they advance the technology by having inductive fans, a monitor inside the machine drum and a sensor-actuated interlocking system to ensure that the concentration is below approximately 300 ppm before the machine loading door, button trap, or filters can be opened.
Both 4th and 5th generation machines represent the latest demonstrated machine design technology that minimizes PCE air emissions from systems using PCE as a solvent. These machines offer the following air mitigation benefits:
Dry-to-dry design that eliminates clothing transfer.
Primary and secondary vapor control systems.
A carbon adsorber capable of reducing the PCE concentration in the cylinder at end of the dry cycle below 300 ppm.
A drying sensor that automatically controls the dry cycle by monitoring the solvent recovery process.
A door locking mechanism that prevents the loading and unloading door of the dry cleaning machine from opening before the end of the dry cycle. (5th generation machines). As previously noted, although this lock-out device provides additional safety for operators, if a machine is allowed to complete the drying cycle, the carbon adsorber of a 4th generation machine provides the same level of PCE emissions control.
Given the 25-plus years of demonstrated use of these two latest generations of PCE machines and reasonable assumption that there are no 1st, 2nd, or 3rd generation machines that are still within their useful life, it would be prudent to require 4th and 5th generation machines to be the only PCE machines allowed to continue to operate.



                                   APPENDIX A
                                       
     PCE Dry Cleaning NESHAP Technology Review Stakeholder Meeting Details
                                       
                                       
The EPA hosted conference call meetings (via Microsoft Teams) with various dry cleaning sector stake holders including state air quality regulators, small business environmental assistance providers' programs (SBEAP) personnel, and industry trade association representatives. The stakeholders were asked to provide general information and updates on the dry cleaning industry and specifically to provide details on any advances in PCE dry cleaning industry practices, processes, or control technologies since 2006. The salient points provided by these stakeholders are summarized in section III of this memorandum.
The dates (in chronological order), times, and attendees of each PCE Dry Cleaning NESHAP stakeholder conference call meeting is provided below.
 Monday March 22, 2021, 12:00 PM ET  -  Dry Cleaning Industry Trade Association Meeting
      
      Nora Nealis, National Cleaners Association, Executive Director
      Mary Scalco Jon Meijer, Dry Cleaning & Laundry Institute, CEO
      Jon Meijer, Dry Cleaning and Laundry Institute, Director
      Brian Storey, EPA, OAR, Project Lead
      Keith Barnett, EPA, OAR, Group Lead
      Barrett Parker, EPA, OAR, Specialist
      Rhonda Wright, EPA, OAR, Community & Tribal Programs Group
      Mike Thrift, EPA, Office of General Counsel, Attorney
      Larry Sorrels, EPA, OAR, Economist, 
      Nathan Pfisterer, EPA, OAR, Economist
      Steven McLeod, RTI International, Contractor
 
      
 Thursday April 22, 2021, 2:00 PM ET  -  Dry Cleaning Small Business Round Table Meeting
      
      Ray Zammit, Complete Laundering Services
      Mary Scalco, Dry Cleaning & Laundry Institute 
      Brian Butler, Dublin Cleaners Inc
      Dru Shields, EnviroForensics
      Rob Hoverman, EnviroForensics & Wisconsin Fabricare Institute
      Rhonda Wright, EPA
      Brian Storey, EPA
      Keith Barnett, EPA
      Tina Ndoh, EPA
      Ryan Callihan, EPA
      Ann Johnson, EPA
      Albert Monroe, EPA
      Kelly Summers, EPA
      Larry Sorrels, EPA
      Lea Carmichael, EPA OSDBU
      Paula Hoag, EPA OSDBU
      Catherine Tunis, EPA OSDBU
      Elnora Thompson, EPA OSDBU
      Harriet Edwards, EPA OSDBU
      Daniel Fagnant, EPA Region 8
      Skip Wilke, Hudson Equipment 
      Mark Stoddard, Indiana Dept. of Env. Management
      Michelle Spitznagel, MA Office of Technical Assistance
      Joe Jaskowski, Michigan Dept. of Environment, Great Lakes, & Energy
      Karen Kajiya-Mills, Michigan EGLE  -  Air Quality Div.
      Mike Nelson, Minnesota Pollution Control Agency
      Nathan Landwehr, Minnesota Technical Assistance Program
      Bob Randolph, Missouri Dept. of Natural Resources, Air Pollution Control Program
      John Podolinsky, Montana Dept. of Env. Quality
      Melissa McGee-Collier, MS Dept. of Env. Quality
      Bryan Williams, MS Dept. of Env. Quality
      Trayce Moore-Thomas, MS Dept. of Env. Quality
      Tony Pendola, NC Dept. of Env. Quality
      Nicholas Onderdonk-Milne, New York State Dept. of Env. Conservation
      Ed Horick III, New York State Dept. of Env. Conservation-Div. of Air Resources
      Sara Johnson, NH Dept. of Env. Services
      Edward Bakos, NJ Dept. of Env. Protection
      Gabe Lorenz, Ohio Air Quality Development Authority
      Brooke Grant, Ohio Air Quality Development Authority
      Susan Foster, PA Dept. of Env. Protection 
      Lucas Hershey, PA Dept. of Env. Protection 
      Nancy Herb, PA Dept. of Env. Protection 
      Steven Hirmer, Performance Labs, Inc.
      Steven McLeod, RTI International
      Phyllis Copeland, SC Dept of Health & Env. Control
      David Miller, Small Business America
      Jong Yu, State of Michigan/AQD/TPU
      Paul Gelpi, Swan Cleaners, Inc.
      Alison Hensley, Tennessee Dept. of Environment & Conservation
      Donovan Grimwood, Tennessee Dept. of Environment & Conservation SBEAP
      Crystal Warren, TN Dept. of Environment & Conservation 
      Nancy Crickman, University of Nevada, Reno
      Bill Hay, Western States Drycleaners & Launderers Association
      Jim Croyle, White Swan Cleaners
      Jeremy Hancher, Widener University SBDC
      Mike Foti, Wisconsin Fabricare Institute
      Steve Moore, Yuhanicks Dry Cleaning
      
      
      
 Tuesday April 27, 2021, 9:30 AM ET  -  North Carolina SBEAP Dry Cleaning Meeting
      
      Tony Pendola, North Carolina SBEAP, Small Business Ombudsman
      Brian Storey, EPA, OAR, Project Lead
      Keith Barnett, EPA, OAR, Group Lead
      Ryan Callihan, EPA, OAR, Economist
      Steven McLeod, RTI International, Contractor
      
 Tuesday April 27, 2021, 2:00 PM ET  -  Illinois State Agency and SBEAP Dry Cleaning Meeting
      
      Dixon Nwaji, Illinois Bureau of Air
      Rick Fiddyment, Illinois SBEAP
      Brian Storey, EPA, OAR, Project Lead
      Keith Barnett, EPA, OAR, Group Lead
      Ryan Callihan, EPA, OAR, Economist
      Steven McLeod, RTI International, Contractor
      
 Wednesday April 28, 2021, 11:00 AM ET  -  Kentucky State Agency Dry Cleaning Meeting
      
      Courtney Shattuck, Kentucky Division of Air Quality 
      Brian Storey, EPA, OAR, Project Lead
      Keith Barnett, EPA, OAR, Group Lead
      Ryan Callihan, EPA, OAR, Economist
      Steven McLeod, RTI International, Contractor
      Notes: 
 On Thursday May 20, 2021, 2:22 PM ET Ms. Shattuck transmitted (via an email to Mr. Storey) information on Kentucky PCE dry cleaning facility counts, types of machine generations, and the types of alternative solvents used at non-PCE dry cleaning locations. 
 Jefferson County (which includes the city of Louisville) has its own separate air program from the state of Kentucky, so the details provided by Ms. Shattuck do not include information for that county.
         
 Wednesday April 28, 2021, 2:00 PM ET  -  Colorado SBEAP Dry Cleaning Meeting
      
      Christine Hoefler, Colorado SBEAP Assistance Coordinator
      Brian Storey, EPA, OAR, Project Lead
      Ryan Callihan, EPA, OAR, Economist
      Rhonda Wright, EPA, OAR, Community & Tribal Programs Group
      Steven McLeod, RTI International, Contractor
      
 Thursday April 29, 2021, 10:00 AM ET  -  New York State Agency Dry Cleaning Meeting
      
      Ed Horick, NYDEP
      Nick Onderdonk-Milne, NYDEP
      Brian Storey, EPA, OAR, Project Lead
      Ryan Callihan, EPA, OAR, Economist
      Rhonda Wright, EPA, OAR, Community & Tribal Programs Group
      Steven McLeod, RTI International, Contractor
      
 Thursday April 29, 2021, 1:00 PM ET  -  Tennessee State Agency and SBEAP Dry Cleaning Meeting
      
      Charles Rowan, TNDEC, Division of Remediation
      Justin Dolzen, TNDEC, Division of Air Pollution Control
      Donovan Grimwood, Tennessee SBEAP Small Business Ombudsman
      Brian Storey, EPA, OAR, Project Lead
      Ryan Callihan, EPA, OAR, Economist
      Rhonda Wright, EPA, OAR, Community & Tribal Programs Group
      Steven McLeod, RTI International, Contractor
      
 Thursday May 6, 2021, 1:00 PM ET  -  California Air Resources Board State Agency Dry Cleaning Meeting
      
      Greg Harris, CARB
      Eugene Rubin, CARB
      Mei Fong, CARB
      Robert Krieger, CARB
      John Katz, EPA Region 9
      Brian Storey, EPA, OAR, Project Lead
      Ryan Callihan, EPA, OAR, Economist
      Larry Sorrels, EPA, OAR, Economist
      Kelly Summers, EPA, OCSPP
      Albert Monroe, EPA, OCSPP
      Amy Shuman, EPA, OCSPP 
      Steven McLeod, RTI International, Contractor
      
      
 Tuesday June 1, 2021, 10:00 AM ET  -  Dry Cleaning and Laundry Institute Trade Association Meeting
      
      Mary Scalo Jon Meijer, Dry Cleaning and Laundry Institute, CEO
      Jon Meijer, Dry Cleaning and Laundry Institute, Director
      Brian Storey, EPA, OAR, Project Lead
      Keith Barnett, EPA, OAR, Group Lead
      Ryan Callihan, EPA, OAR, Economist
      Larry Sorrels, EPA, OAR, Economist
      Kelly Summers, EPA, OCSPP
      Albert Monroe, EPA, OCSPP
      Steven McLeod, RTI International, Contractor
      
      
 Thursday July 22, 2021, 12:00 PM ET  -  Korean Dry Cleaning Association Trade Group Meeting
      
      Paul Choe, Korean Dry Cleaning Association
      Brian Storey, EPA, OAR, Project Lead
      Keith Barnett, EPA, OAR, Group Lead
      Ryan Callihan, EPA, OAR, Economist
      Larry Sorrels, EPA, OAR, Economist
      Kelly Summers, EPA, OCSPP
      Albert Monroe, EPA, OCSPP
      Steven McLeod, RTI International, Contractor


